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Bridging the GAP: Bringing Big Food Safety Regulations to Small Farms

For large farming operations, food safety audits are commonplace. Many buyers require them before purchasing produce. However, small farms are rarely inspected by auditors, because the cost of implementing a safety plan can be too expensive.

That’s where Bridging the GAPs – a program designed to help small and mid-sized growers find a way to meet food safety guidelines – comes in.

Organized by the Washington State Department of Agriculture (WSDA), the initiative will allow modest-sized operations to reach broader markets such as schools, grocery stores and restaurants, most of which now require Good Agricultural Practices certification.

Good Agricultural Practices (GAPs) is a set of protocols approved by the U.S. Department of Agriculture that farmers can follow to prove they’re growing and harvesting in a way that minimizes the risk of crop contamination.

However, because these standards require extra time, equipment and sometimes land, they are often daunting or even prohibitive to small and mid-sized farmers.

At a farm in Bellingham, WA this month, farmers, state and local health officials and community members gathered to begin a dialogue on how to make GAPs easier for modest farms to swallow. The group toured Cedarville Farms, a family-operated, 7-acre organic farm, in order to get a first-hand look at the obstacles that stand between small farms and GAPs certification.

At the event, auditors and food safety experts spoke about what it takes to meet these requirements. Key elements include:

– Employees must be educated in sanitation practices and have access to clean hand-washing and waste facilities

– Sick workers are not allowed to handle food or processing surfaces

– Irrigation water has been tested and does not flow from an uphill source that could be contaminated with human or animal feces

– Livestock are not in close proximity to crops, and fences around fields keep out wild animals

– Raw manure is applied to crops at least 120 days before harvesting and records are kept of composted manure treatment

– Records are kept of what crops are planted in what field, what date they’re planted and harvested and where they were sold, so that produce can be traced back to its origin in the case of a recall

But farmers weren’t the only ones doing the learning. Representatives from WSDA’s Fruit and Vegetable Inspection Program, Food Safety and Organics programs and Farm-to-School initiative made it clear that they were there to learn what aspects of these policies are difficult – or even impossible – to achieve on a small farm with diversified crops.

For example, GAPs regulations specify that animals must be housed at least a half-mile from growing fruits and vegetables. But on a farm such as Cedarville, which is 1/10 of a square mile, this would mean that either the livestock or the produce would have to go.

Chuck Dragoo, district assistant manager of GAPs monitoring, explained that alternatives exist for many of these regulations. In this case, a natural barrier between animals and crops – such as a road or drainage ditch – would be acceptable.

That goes for controlling potentially contaminated runoff as well, he explained.

“We like to see a natural barrier between compost piles and farmlands,” he explained. Fields should also be protected from water flowing from ponds or streams, and sewage must be properly contained.

Cedarville Farms’ chickens are located feet from the zucchini beds, with no natural barriers, a situation that Dragoo said give him “heartburn” as an auditor, and would need to be remedied before the farm were to undergo a GAPs audit (something it has not yet done).

Another problem farmers raised was the requirement that storage containers be new or sanitized before use, and not stacked if they’ve touched the ground. Buying new crates is expensive, and not stacking clean crates that have been on the ground next to crops drags out the harvesting process.

For this problem, auditors – who again deal mostly with large, commodity farms – didn’t know the solution. One farmer, however, suggested laying out a tarp on which to set containers to keep them clean, a solution Dragoo said would work well.

This sort of question and suggestion exchange created a way for auditors and growers to work through problems they often didn’t know existed before talking to one another at the meeting.

“Auditors need to know what the reality is on small farms,” Tricia Kovacs, a WSDA education and outreach specialist, told the group. “We need to start serving smaller and midsized farms better in terms of GAPs certifications, and it hasn’t come up a lot yet,” she said.

Farmers expressed hope that after this gathering, regulatory officials would have a better understanding of what it takes for them to become eligible for certification.

“As is made evident by this tour and the conversations that are occurring, the cultures are very different and they were very unfamiliar with many of the sets of problems that we’re confronted with,” said Greg Reed, a farmer on Vashon Island who is currently developing a food safety plan so that he can sell to the school district there.

But, he says, it’s a two-way street. “We [farmers] are trying to increase our awareness of what’s going on,” he told Food Safety News. “We’re unfamiliar with the culture that they’re used to seeing, and so we need to come together in the middle somewhere.”

One of the things these farmers are unfamiliar with is the documentation needed to prove that they’re taking measures to meet GAPs. Letting raw manure compost for 120 days doesn’t mean anything if you don’t record the dates on which it was added, turned, checked for temperature and then applied to plants, Dragoo explained.

And that goes for documenting any part of the process, whether it’s results of water tests or where and when each crop was planted and harvested.

Mike Finger, owner of Cedarville Farms, who has been working toward GAPs certification for almost a year, says that viewing wildlife as a danger rather than an asset was a hard adjustment.

“When I got here and saw that the pond had ducks and fish and beaver, you know, I’m a wildlife biology major and I thought ‘Way cool, man!’ Then I thought, ‘Cool, I’ve got a built-in fish fertilizer. Every time I irrigate I’m getting all this poop sprayed on the crops,” he recounted. “And now it’s like ‘Oh my God. Let’s nuke the whole thing. Let’s just cover it with a concrete lid.”

The message of the day from food safety officials was don’t be intimidated. There’s a happy medium between raw feces as fertilizer and filling in the pond, and with some work and compromise, it’s do-able.

“A lot of the standards are written in such a way that it allows that interpretation and it allows flexibility, so I just want to remind everybody not to close your mind on GAPs certification or organic certification,” said Brenda Book, program manager for WSDA’s Organic Program, which requires a separate certification from GAPs.

Despite reassurance from officials, however, some farmers remained skeptical about their ability to meet GAPs standards.

When asked how many thought they would be able to attain GAPs certification within the next year, only one farmer raised her hand. When the timeline was extended to 3 years, a handful more said they could, but this group was still in the minority.

Cost seems to be one of the biggest barriers. Audits cost money, as does getting clean water to fields for hand washing, maintaining bathroom facilities, and setting up covered facilities for harvested food so that animals can’t reach them.

“I know as a farmer I’m very willing to invest money to make my farm safer,” said Finger. “But when Chuck [Dragoo] said today that some operations might be required to have closed facilities, I said ‘OK, now the rubber’s really meeting the road.’ That’s where this all gets very interesting for small-scale farmers is those sort of investments and infrastructure. Those are going to at least make it hard for people to get in.”

When Food Safety News asked Reed if he found GAPs certification daunting, he replied, “Yes, absolutely.”

But state officials made it clear that they would be bringing farmer’s concerns back to the office to share with other auditors and try to shape a system more sensitive to small farm capabilities.

“This is what Bridging the GAPs project is all about. If we hear concerns that you have as far as the ability to market your commodities and be competitive in the marketplace, those are questions I’d be more than willing to take back to our program managers and say ‘Listen, I think we need to talk about this and give them some options.’ ”

More information on GAPs auditing and a copy of the audit checklist is available on the Washington State Department of Agriculture’s website.

Thanks to Food Safety News for covering the event and acknowledging the complexities around these topics. We’d also like to thank our partners, Tilth Producers of Washington and Washington State University Extension, for featuring Good Agricultural Practices as part of the Farm Walk Series. Additionally, we would like to extend our appreciation to Mike Finger of Cedarville Farm for welcoming farmers, auditors and educators to his farm to engage in this discussion.

Sarah

I’m not in disagreement with there being regulations and audits on smaller farms. Here in NY, I feel like the smaller farms actually have more restrictions and audits. What upsets me is that, although there supposedly are regular checkups on larger scale agribusiness, it rarely happens. Factory farms literally get away with murder behind closed and locked doors.

“When I got here and saw that the pond had ducks and fish and beaver, you know, I’m a wildlife biology major and I thought ‘Way cool, man!’ Then I thought, ‘Cool, I’ve got a built-in fish fertilizer. Every time I irrigate I’m getting all this poop sprayed on the crops,” he recounted. “And now it’s like ‘Oh my God. Let’s nuke the whole thing. Let’s just cover it with a concrete lid.” This quote sums it up for me. GAPS simply will not work for ecological farmers, which should be all farmers since we all rely on ecological processes. Farming is a living system- you can’t deny that. GAPS will only lead to more sterilized farming systems, fenced out widlife with nowhere to go, and destroying the most sustainable forms of agriculture- ones which integrate livestock for fertility, natural weed control, and added income. I can’t see why any smart small to medium-scale farmer would even bother. Let the big guys play in the low price space of wholesaling with their sterile, input-heavy, ugly looking forms of farming.
GAPS don’t want you to have farm dogs such as livestock guard dogs, barn cats to control rodents, no school groups, no public tours. They want farming to move even further away from being part of the community towards an ever more sterile, hydroponic, enclosed system of “agribusiness”. Read some Wendell Berry and Gene Logsdon and forget the GAPS hype.

Mary

Yes, the medium-scale farmer Jensen Farms of Colorado paid no attention to the GAPs hype and relied on ecological processes. Sterile, input-heavy farming was not for them. Listeria is “natural,” after all. Thirty dead and 139 hospitalized? Just collateral damage on the road to sustainability.http://www.fda.gov/Food/FoodSafety/FoodborneIllness/ucm276247.htm